CRA STATEMENT
COMMUNITY REINVESTMENT ACT POLICY
BACKGROUND
The Community Reinvestment Act of 1977 ("CRA") was enacted as Title VIII of the Housing and Community Development Act of 1977. All federal banking agencies adopted regulations implementing CRA on November 6, 1978, and it is covered under Regulation BB. The CRA pertains to a bank’s responsibility to help in meeting all types of credit needs, including consumer and commercial credit needs, with a special emphasis placed on real estate lending activities and the needs of low- and moderate-income neighborhoods.
On January, 1996, CRA was amended in scope and adopted by all federal regulatory agencies. The amended regulation created three methods in which a bank could be “evaluated” by its primary regulatory agency- in the case of Doctors’ Bancorp and Beach Business Bank, the FDIC. The three methods of review are: three-pronged, small bank, and strategic plan. Doctors’ Bancorp and Beach Business Bank fall under the "small bank" method.
Small Banks A bank with total assets less than $250 million may elect to be judged under the small bank standards. For a bank that is owned by a holding company, the holding company s total bank and thrift assets must be less than $1 billion.
Under the small bank test, the regulators will consider the bank’s loan-to-deposit ratio, with adjustments for any seasonality that exists. They also evaluate the bank’s other lending activities, such as originations of loans for sale in the secondary market. They will also consider any community development loans and similar investments the bank may make in these areas.
The regulators also evaluate the proportion of the small bank’s total lending to borrowers in its assessment area, and the distribution of its loans among people of different income levels, and among businesses and farms of different sizes. Small businesses are defined as those businesses and farms with gross annual revenues of $1 million or less.
Determining a Small Bank Rating - There is no measure of precision built into the evaluation assessment by the regulators. While the amended CRA is intended to be more objective it creates a strong element of “examiner judgment” in the assessment process. A small bank will receive a “satisfactory” rating if it demonstrates a “reasonable” loan-to-deposit ratio and “reasonable” distribution of loans among different income levels of people and different sizes of businesses and farms and no CRA complaints.
BANK POLICY
Beach Business Bank (the “Bank”) will work diligently to conform to the letter and spirit of the CRA. The Bank recognizes that this requires an active approach in determining and meeting the community’s banking needs, including the credit needs of low- and moderate-income areas. The Bank will also strive to maintain accurate processes with which to gather and analyze its data.
FAIR LENDING NOTICE
THE HOUSING FINANCIAL DISCRIMINATION ACT OF 1977
It is illegal to discriminate in the provision of or in the availability of financial assistance because of the consideration of:
1. Trends, characteristics or conditions in the neighborhood or geography surrounding a housing accommodation, unless the financial institution can demonstrate in the particular case that such consideration is required is an unsafe and unsound business practice; or
2. Race, color, religion, sex, marital status, national origin or ancestry.
It is illegal to consider the racial, ethnic, religious or national origin content of a neighborhood or geographic area surrounding a housing accommodate whether or not such composition is undergoing change, or is expected to undergo change, in appraising a housing accommodation or in determining whether or not, or under what terms and conditions, to provide financial assistance.
These provisions govern financial assistance for the purpose of the purchase, construction, rehabilitation or refinancing of one-to-four-unit family residence occupied by the owner and for the purpose of the home improvement of one- to four-unit family residence.
If you have questions about your rights, or if you wish to file a complaint with the management of this financial institutions or:
California Department of Financial Institutions
45 Fremont Street
Suite 1700
San Francisco, CA 94105-2219
415-263-8500
HOME MORTGAGE DISCLOSURE ACT (HMDA) NOTICE
The HMDA data about our residential mortgage lending are available for review. The geographic distribution of loans and applications: race, gender, and income of applications of borrowers; and information about loan approvals and denials.
Inquires may be emailed to
info@beachbusinessbank.com regarding the locations where HMDA data may be inspected.
FUNDS AVAILABILITY
Our general policy is to allow you to withdraw funds deposited in your account on the
first business day after the day we receive your deposit. Funds from electronic direct deposits will be available on the day we receive the deposit. In some cases, we may delay your ability to withdraw funds beyond the first business day. Then, the funds will generally be available on the
second business day after the deposit.
US PATRIOT ACT
Important information about account opening procedures.
To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account.
What this means for you – when you open an account, we will ask for your name, address, date of birth, and tax identification number and other information that will allow us to identify you.
We may also ask to see your driver’s license or other identifying document.
Transaction Account Guarantee Program
|
